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041.pdf
A court order from the Southern District of New York in the JP Morgan Chase & Co. Derivative Litigation (Case No. 1:23-CV-03903), signed by Judge Jed S. Rakoff on November 7, 2023. The order grants attorney Christopher J. Orrico of Grant & Eisenhofer P.A. admission to practice pro hac vice to represent the plaintiff, Operating Engineers Construction Industry and Miscellaneous Pension Fund.
038-03.pdf
This document is a proposed court order filed on August 8, 2023, in the JP Morgan Chase & Co. Derivative Litigation (Case 1:23-cv-03903). It grants attorney Christopher J. Orrico of Grant & Eisenhofer P.A. admission pro hac vice to represent the plaintiff, Operating Engineers Construction Industry and Miscellaneous Pension Fund, before Judge Jed S. Rakoff in the Southern District of New York.
037.pdf
This document is a Motion for Admission Pro Hac Vice filed on August 8, 2023, in the JP Morgan Chase & Co. Derivative Litigation. Attorney Christopher J. Orrico of Grant & Eisenhofer P.A. requests permission to represent the plaintiff, Operating Engineers Construction Industry and Miscellaneous Pension Fund, in the Southern District of New York. The attorney attests to his good standing in New York and Connecticut.
037-03.pdf
This document is a proposed order for the admission pro hac vice of attorney Christopher J. Orrico in the 'In re JP Morgan Chase & Co. Derivative Litigation'. It grants Orrico, of the firm Grant & Eisenhofer P.A., permission to represent the plaintiff, Operating Engineers Construction Industry and Miscellaneous Pension Fund, in the Southern District of New York. The document provides Orrico's contact information and confirms his standing in the bars of New York and Connecticut.
037-01.pdf
This document is a declaration filed on August 8, 2023, by attorney Christopher J. Orrico of Grant & Eisenhofer P.A. requesting admission pro hac vice in the JP Morgan Chase & Co. Derivative Litigation (Case No. 1:23-CV-03903). Orrico attests to his good standing in New York and Connecticut and confirms he has no criminal or disciplinary record. He represents the Operating Engineers Construction Industry and Miscellaneous Pension Fund in this matter.
EFTA00032215.pdf
This document is a series of email chains between attorney Michael Bachner and government prosecutors (including one named Alex) regarding an 'Attorney Proffer' for a client referred to as Ms. [Redacted]. The correspondence, dating from February to June 2020, discusses the logistics of scheduling interviews, which were complicated by the onset of the COVID-19 pandemic. Key details emerging from the proffer discussions include the client admitting to visiting Epstein's New York and Palm Beach properties, as well as staying at Epstein's Paris apartment with her husband on one occasion. No flight logs or aircraft data are contained in this document.
EFTA00031733.pdf
This document is a judgment from the European Court of Human Rights regarding the case of Babar Ahmad and Others v. The United Kingdom, concerning the extradition of six terrorism suspects (including Abu Hamza) to the United States. The applicants argued that extradition would violate Article 3 of the European Convention on Human Rights due to the risk of solitary confinement at ADX Florence and the possibility of grossly disproportionate life sentences. The Court unanimously ruled that extradition would not violate Article 3, finding that conditions at ADX Florence and the potential sentences did not amount to inhuman or degrading treatment.
EFTA00031101.pdf
An email dated November 19, 2019, with the subject 'MCC' (Metropolitan Correctional Center). The sender shares a link to a WFSB news video regarding Jeffrey Epstein's death and notes seeing the report on a Connecticut CBS affiliate. The date coincides with the indictment of the two prison guards charged in connection with Epstein's suicide.
EFTA00025392.pdf
This document is a Law360 email newsletter from July 21, 2020, summarizing various legal news stories. Key topics include the resentencing of Sheldon Silver, a harassment suit at Fox News, and the shooting at the home of Judge Esther Salas, which notes her involvement in a case concerning Deutsche Bank's ties to Jeffrey Epstein. The newsletter also covers various corporate litigations, bankruptcy rulings, and general counsel appointments.
EFTA00010224.pdf
This document is a subpoena issued by the defense team of Ghislaine Maxwell (Case No. 20CR330) to an undisclosed recipient (likely an administrator of the Epstein Victims' Compensation Program). The subpoena demands the production of materials submitted by accusers to the EVCP, including claim forms, communications, payment records, and releases. Attached to the subpoena is the 'Independent Epstein Victims' Compensation Program Protocol' (dated May 29, 2020), which details the rules, eligibility requirements, and procedures for victims seeking compensation from the Epstein Estate, noting that the program is voluntary, independent, and confidential.
EFTA00010045.pdf
This document is a subpoena issued by Ghislaine Maxwell's defense team in November 2021, commanding the production of records from the Epstein Victims' Compensation Program (EVCP). The subpoena seeks all materials submitted by accusers, communications between the EVCP and accusers, records of payments, and executed releases. Attached to the subpoena is the 'Protocol' for the EVCP dated May 29, 2020, which outlines the independent program's purpose, eligibility requirements, claims administration process, and confidentiality rules for compensating victims of Jeffrey Epstein.
DOJ-OGR-00001006.jpg
This document is a court transcript from April 1, 2021, for a hearing in the case of United States v. Ghislaine Maxwell, presided over by Judge Nathan. The transcript records the appearances of the legal counsel for both the defendant, Ghislaine Maxwell, and the U.S. government. The government's counsel also requests permission for staff from the U.S. Attorney's office to be dialed into the hearing due to technical issues with an overflow line from Connecticut.
DOJ-OGR-00021057.jpg
This document is page 'ix' from a legal filing, specifically Document 59 in Case 22-1426, dated February 28, 2023. It serves as a table of authorities, listing numerous U.S. court cases with their legal citations and corresponding page references within the larger document. The cases cited span from 1926 to 2017 and originate from various federal district and circuit courts.
DOJ-OGR-00020596.jpg
This document is a letter dated July 28, 2022, from an appellate counsel at the law firm Aidala, Bertuna & Kamins, P.C. to the Clerk of Court. The lawyer, newly assigned to Ghislaine Maxwell's appeal, requests an extension to file the Appellant's Brief, moving the deadline from October 14, 2022, to January 30, 2023. The justification for the request includes the voluminous nature of the case record (over 3,800 pages of transcripts and 738 docket entries) and the fact that the lawyer has been unable to meet with Maxwell following her recent transfer to a prison in Tallahassee, Florida.
DOJ-OGR-00018494.jpg
This document is a page from a court transcript (dated August 10, 2022) featuring the direct examination of a witness named McHugh. The testimony details financial transactions from June 18, 2007, specifically an internal JP Morgan transfer of $7.4 million followed immediately by a wire transfer of $7,352,825 to Sikorsky Aircraft. The wire transfer references 'Air Ghislaine Inc.' and is described as the purchase of a green Sikorsky S76C helicopter.
DOJ-OGR-00015172.jpg
This document is a claim form for the Epstein Victims' Compensation Program, dated June 26, 2020. It is signed by 'SM', a legal representative, on behalf of a claimant whose name has been redacted. The form was notarized by Deborah Cuffe in Broward County, Florida on the same day.
DOJ-OGR-00002323.jpg
This document is page 3 (Table of Authorities) of a legal filing (Document 126) from Case 1:20-cr-00330-AJN, filed on January 25, 2021. It lists legal precedents (cases) and statutes cited in the brief, including Supreme Court cases like Duren v. Missouri and Second Circuit cases like United States v. Jackman. The document bears a Department of Justice Bates stamp DOJ-OGR-00002323.
DOJ-OGR-00002281.jpg
This document is page 'ii' (3 of 19) of a legal filing from January 25, 2021, related to Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). It is a 'Table of Authorities' section listing various legal precedents (cases) cited in the main document, including United States v. Halper and United States v. Burke. The document bears a Department of Justice Bates stamp 'DOJ-OGR-00002281'.
DOJ-OGR-00002281(1).jpg
This document is a Table of Authorities page (Page 3 of 19) from a court filing dated January 25, 2021, in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). It lists twenty-one legal precedents (cases) cited in the brief, primarily from the Second Circuit and D.C. Circuit, covering dates from 1964 to 2011. The document bears a Department of Justice Bates stamp DOJ-OGR-00002281.
DOJ-OGR-00021658.jpg
This document is page 11 of 93 from a legal filing (Case 22-1426), dated June 29, 2023. It is a 'Table of Authorities' listing various legal precedents (case law) cited in the main brief, including 'United States v. Salameh', 'United States v. Teman', and 'United States v. Vickers'. The footer indicates it is a Department of Justice document (DOJ-OGR-00021658).
DOJ-OGR-00010129.jpg
This document is page 4 of a legal filing (Document 522, filed April 6, 2012) discussing legal ethics, specifically the standard of knowledge required for an attorney to report fraud or perjury to a tribunal. It cites a case involving an attorney named 'Doe' where discipline was reversed because 'actual knowledge' of perjury is required, not just strong suspicion. The author of this document identifies themselves in a footnote as the expert witness who testified for Doe in the underlying Connecticut disciplinary hearing.
DOJ-OGR-00010128.jpg
This document is page 3 of a legal filing from April 6, 2012, in case 1:09-cr-00581-WHP. It discusses a lawyer's ethical obligations under various New York Rules of Professional Conduct, specifically concerning the duty to act upon knowledge of false evidence, fraudulent conduct, or improper conduct toward a jury. The document emphasizes that the standard for a lawyer's required knowledge is "actual knowledge" and cites the 1988 Second Circuit case, *Doe v. Federal Grievance Committee*, to illustrate this legal principle.
DOJ-OGR-00009450.jpg
This document is a page from a legal filing (originally 2012, refiled 2022) discussing attorney ethics regarding the reporting of perjury (fraud on the tribunal). It cites a precedent case involving 'Doe,' arguing that an attorney must have actual knowledge, not just strong suspicion, of perjury before a duty to disclose arises. The author of this text notes in a footnote that they served as the expert witness for 'Doe' in a Connecticut disciplinary hearing.
DOJ-OGR-00009449.jpg
This legal document, page 3 of 29 from a court filing, discusses a lawyer's ethical obligations under various New York Rules of Professional Conduct. It emphasizes that a lawyer's duty to take remedial action, such as disclosing fraudulent conduct to a court, is triggered only by "actual knowledge," a subjective standard. The document cites the 1988 Second Circuit case 'Doe v. Federal Grievance Committee' to support the argument that a mere belief of wrongdoing is insufficient to compel disclosure.
DOJ-OGR-00002955.jpg
This document is page 21 of a Table of Authorities from a legal filing (Document 204) in Case 1:20-cr-00330-PAE, which corresponds to the trial of United States v. Ghislaine Maxwell. The page lists various legal precedents (case law citations) ranging from 'United States v. Rahimi' to 'United States v. Rosa' used to support legal arguments in the main brief. The document bears the Bates stamp DOJ-OGR-00002955.
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